Sedima, S. P. R. L. v. Imrex Co., Inc.

Summary

Justice White's majority opinion held that a private civil RICO action requires neither a prior criminal conviction nor a distinct racketeering injury separate from the harm caused by the predicate acts. A plaintiff must allege the elements of the RICO violation and injury to business or property caused by the conduct constituting that violation. The Court reversed and remanded without deciding whether the alleged predicate acts occurred or constituted a pattern. Justice Marshall, joined by Justices Brennan, Blackmun, and Powell, dissented, arguing that civil RICO requires a distinct commercial injury arising from racketeering's economic power rather than merely the direct injury from predicate offenses. Justice Powell also dissented separately, emphasizing Congress's organized-crime focus and advocating a narrower interpretation, particularly of the pattern requirement.